Re: ERO #013-4143 The…

Re: ERO #013-4143

The current review of Ontario’s Endangered Species Act, 2007 (ESA) should be utilized to better protect the hundreds of species at risk in the Province and their habitat. It must not be used as a means of degrading that protection, which, alarmingly, appears to be the intent of the ministry’s 10th Year Review Discussion Paper.

The ESA was seriously weakened in 2013 with the adoption of exemptions to the prohibition on harming species at risk or their habitat. The current process appears to be aimed at further “streamlining” of procedures in favour of developers, and attacking the science-based nature of COSSARO assessments.

Therefore, I strongly oppose such measures and instead urge the following:

a) Eliminate the exemptions that were introduced in 2013.

b) Maintain the science-based COSSARO listing process. Listing should not be at the minister’s discretion.

c) Do not lengthen the process for COSSARO assessment and listing. It is already too long to the detriment of species at risk.

d) Do not change the 5-year review of progress process. We need to know if a recovery strategy is working, so that changes can be made when necessary.

e) Do not lengthen the timelines for the preparation of recovery strategy and government response documents. They are often late.

f) Developers must not be able to pay into a fund in order to allow them to harm species at risk and their habitat.

g) Protection of habitat for endangered and threatened species must be automatic, not at the minister’s discretion.

h) Habitat regulations can be very important to species with a limited range because they may included areas that were formerly but are not now occupied by the species, as well as areas to which they may expand their range.

i) Provide sufficient staff and funding to endure that various documents are prepared on time, strategies are implemented fully, and compliance monitoring is carried out.

j) Ensure that the ESA is fully implemented, which is not currently the case.

These steps will help ensure that Act is strengthened and species at risk and their habitat are better protected.